SPA-LOGO-TRANSPARENT

Privacy Policy

1. Introduction and Overview.

This Privacy Policy provides a comprehensive description of how Serbian Philanthropic Association (“SPA,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information. It applies to any online location that links to this Privacy Policy, including our website available at
https://serbianphilanthropicassociation.org or offline location that makes this Privacy Policy available to you (collectively, the “SPA Services”).

By using the SPA Services, you agree to our Terms of Use and with our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the SPA Services.

If you have any questions or wish to exercise your rights and choices, please contact us as set out
in the “Contact Us” section. If you are a Nevada resident, California resident, or data subject in Europe, please see the additional disclosures at the end of this Privacy Policy.

For personal data transferred from the United Kingdom, the European Union, and Switzerland, we will provide appropriate safeguards, such as through the use of standard contractual clauses.

 

2. Information Collection.

A.    Information You Provide.

We collect information about you when you access and use the SPA Services, including information you provide when you submit a membership or volunteer application, sign up for our newsletter, access our content, make a donation, or contact us for customer support. The categories of information we collect include:

  • Contact Data, including your first and last name, email address, and postal address.
  • Demographic Data, including your age and city and country of residence.
  • Profile Data, including the type of projects you’re interested in, other non-profits you’re involved with, and your preferences and favorites.
  • Content, including content within any messages you send to us (such as feedback or information you provide in your membership or volunteer submission form).
  • Fundraiser and donor information, including information in connection with your registration for an event/fundraiser, and information related to your donations (how you found SPA, your donation amount, and if you are making a gift in honor of anyone).
  • Employment and Education Data, including your education history and occupation
    when you submit a membership or volunteer submission form.

If you become a member of make a donation, your billing data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code is collected by our payment processors as necessary to process your payments and not by us. We receive confirmation of successful transfers from our payment processors.

You may choose to voluntarily provide other information to us that we do not request, and, in
such instances, you are solely responsible for such information.

 

B.    Information Collected Automatically.

In addition, we automatically collect information when you use the SPA Services. The categories of information we automatically collect include:

  • Service Use Data, including data about features you use, pages you visit, advertisements and emails you view, products and services you view and purchase, the time of day you
    browse, and your referring and exiting pages.
  • Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language
    settings, and device identifiers such as an IP address and Ad IDs.
  • Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

The types of tracking technologies we use to automatically collect information include:

  • Log Files, which are files that record events that occur in connection with your use of the SPA Services.
  • Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the SPA Services. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
  • Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising both on and off the SPA Services, and provide you with additional functionality, such as the ability to connect our SPA Services with your social media account.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

 

C.    Information from Other Sources.

We may also collect information from other social media platforms when you interact with our SPA accounts on those networks.

 

3. Use of Information.

We collect and use information about you in accordance with the practices described in this Privacy Policy or as permitted by applicable law, including as follows:

  • Operating and managing our SPA Services, including planning and promoting events, collecting donations and providing scholarships.
  • Performing services requested by you, such as responding to your comments, questions, and requests, considering your membership and volunteer applications, and processing transactions.
  • Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
  • Preventing and addressing fraud, breach of policies or terms, and threats or harm.
  • Monitoring and analysing trends, usage, and activities.
  • Improving the SPA Services and other SPA websites, apps, marketing efforts, products and services.
  • Developing and sending newsletters, advertising, and communications about our and other entities’ news, events, and services.
  • Soliciting donations to SPA, conducting fundraisers and promotions.
  • Fulfilling any other purpose at your direction.
  • With notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

 

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

  • Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
  • Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
  • Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the SPA Services or anyone else.
  • Facilitating Requests. We share information at your request or direction.
  • Consent. We share information with notice to you and your consent.

Without limiting the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law.

For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

 

5. Other Parties.

We offer parts of the SPA Services through websites, platforms, and services operated or controlled by other parties. Links and hyperlinks from the SPA Service may not be operated or controlled by us.

Please note that when you interact with other parties, including when you leave our SPA Services, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their ownpolicies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

 

 

6. Analytics and Advertising.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own SPA Services (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the SPA Services and your rights and choices regarding analytics and Interest-based Advertising please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

 

7. Your Rights and Choices.

       

A.    Correction/Updating Information.

If you have donated to us, you may access, update, or remove certain information that you have provided to us by sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use certain information about you or associated with your donation for record keeping integrity, as well as to prevent fraud, collect any fees owed, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

B.    Tracking Technology Choices.

  • Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
  • Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Please be aware that if you disable or remove tracking technologies some parts of the SPA Services may not function correctly.

 

C.    Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

       D.    Communications.

  • E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
  • Calls. You can opt-out of receiving calls to your phone number at any time by requesting to opt-out during any call you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of calls.

Please note that your opt out is limited to the email address and/or phone number used and will not affect subsequent subscriptions.

8. Your California Privacy Rights.

Residents of California may request (i) a list of the categories of personal information disclosed by us to third parties for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

9. Your European Privacy Rights.

A.    Role.

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). SPA acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.

B.    Lawful Basis for Processing.

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.

C.    Your Data Subject Rights.

You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, please contact us as described in the “Contact Us” section below and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.

Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, you may contact us as set out in the “Contact Us” section. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.

10. Children’s Online Privacy.

 

SPA recognizes the importance of protecting the privacy of children online.  The SPA Services are intended for general audiences, and is not directed to children. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, contact us at spg.org.team@gmail.com. We will remove the personal information in accordance with COPPA.

11. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

12. International Transfer.

SPA is based in the U.S. and the information we collect is governed by U.S. law.  If you are accessing the SPA Services from outside of the U.S., please be aware that information collected through the SPA Services may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the SPA Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. For personal data transferred from the European Union, United Kingdom, or Switzerland, we will provide appropriate safeguards, such as through use of standard contractual clauses.

13. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our SPA Services indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

14. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us by email at:  spg.org.team@gmail.com.